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ICRAS Tracking and OMB Number: (1394.32) 1845-0013 Revised: 09/10/2013

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification 

1. Explain the circumstances that make the collection of information necessary. Identify

any legal or administrative requirements that necessitate the collection. Attach a hard 

copy of the appropriate section of each statute and regulation mandating or authorizing 

the collection of information, or you may provide a valid URL link or paste the 

applicable section. Please limit pasted text to no longer than 3 pages. Specify the review 

type of the collection (new, revision, extension, reinstatement with change, reinstatement 

without change). If revised, briefly specify the changes. If a rulemaking is involved, 

make note of the sections or changed sections, if applicable.

The Department of Education (ED) is submitting the ED Form 799 for approval.

The information collected on the ED Form 799 is needed to pay interest and 

special allowance to holders of Part B loans, for internal financial reporting, 

budgetary projections, and for audit and lender reviews by ED, General 

Accounting Office (GAO) and Department of Treasury.

The legal authority for collecting this information is Title IV, Part B of the Higher 

Education Act of 1965, as amended by the Higher Education Reconciliation Act 

of 2005 (“the HERA”), (Pub.L. 109-171). ED is requesting the continual 

approval for regulatory sections 682.304, 682.414 and 682.515.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a 

new collection, indicate the actual use the agency has made of the information received 

from the current collection.

The ED Form 799 is used by lenders participating in the Part B programs to 

request payment of interest and special allowance on loans outstanding. Lenders 

report on the ED Form 799 quarterly (March, June, September, and December).

The information on the ED Form 799 is also used by ED to capture detailed 

information to enhance departmental reporting for budgetary projections, 

program planning and evaluations, departmental audits, and financial and 

statistical reporting on Part B programs.
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ICRAS Tracking and OMB Number: (1394.32) 1845-0013 Revised: 09/10/2013

If the information is not collected, ED is unable to make payments to lenders for 

interest and special allowance, nor provide a comprehensive, analytical analysis 

on lenders and their portfolio of loans.

3. Describe whether, and to what extent, the collection of information involves the use of 

automated, electronic, mechanical, or other technological collection techniques or forms 

of information technology, e.g. permitting electronic submission of responses, and the 

basis for the decision of adopting this means of collection. Also describe any

consideration given to using technology to reduce burden.

The data is submitted to the Financial Management System (FMS) via on-line 

data entry or file transfer protocol (FTP).

4. Describe efforts to identify duplication. Show specifically why any similar information 

already available cannot be used or modified for use for the purposes described in Item 2

above.

This information is only partially captured by the National Student Loan Data 

System (NSLDS) and does not allow them to accurately calculate lender 

subsidies. 

5. If the collection of information impacts small businesses or other small entities, describe 

any methods used to minimize burden. A small entity may be (1) a small business which 

is deemed to be one that is independently owned and operated and that is not dominant in 

its field of operation; (2) a small organization that is any not-for-profit enterprise that is 

independently owned and operated and is not dominant in its field; or (3) a small 

government jurisdiction, which is a government of a city, county, town, township, school 

district, or special district with a population of less than 50,000.

Collection of this information does not involve small business.

6. Describe the consequences to Federal program or policy activities if the collection is not 

conducted or is conducted less frequently, as well as any technical or legal obstacles to 

reducing burden.

If collection of this information were conducted less frequently, it would delay 

payments to lenders mandated by statute.
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ICRAS Tracking and OMB Number: (1394.32) 1845-0013 Revised: 09/10/2013

7. Explain any special circumstances that would cause an information collection to be 

conducted in a manner:

 requiring respondents to report information to the agency more often than quarterly;

 requiring respondents to prepare a written response to a collection of information in 

fewer than 30 days after receipt of it;

 requiring respondents to submit more than an original and two copies of any 

document;

 requiring respondents to retain records, other than health, medical, government 

contract, grant-in-aid, or tax records for more than three years;

 in connection with a statistical survey, that is not designed to produce valid and 

reliable results than can be generalized to the universe of study;

 requiring the use of a statistical data classification that has not been reviewed and 

approved by OMB;

 that includes a pledge of confidentiality that is not supported by authority established 

in statute or regulation, that is not supported by disclosure and data security policies 

that are consistent with the pledge, or that unnecessarily impedes sharing of data with 

other agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can demonstrate that it has instituted procedures to 

protect the information’s confidentiality to the extent permitted by law.

The collection of this information will be conducted in accordance with the 

guidelines in 5 CFR 1320.5
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ICRAS Tracking and OMB Number: (1394.32) 1845-0013 Revised: 09/10/2013

8. As applicable, state that the Department has published the 60 and 30 Federal Register 

notices as required by 5 CFR 1320.8(d), soliciting comments on the information 

collection prior to submission to OMB. Summarize public comments received in 

response to that notice and describe actions taken by the agency in response to these 

comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the 

availability of data, frequency of collection, the clarity of instruction and record keeping, 

disclosure, or reporting format (if any), and on the data elements to be recorded, 

disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or 

those who must compile records should occur at least once every 3 years – even if the 

collection of information activity is the same as in prior periods. There may be 

circumstances that may preclude consultation in a specific situation. These 

circumstances should be explained.

No consultation was made with outside organizations regarding the ED Form 799 

because there were no changes to the form. The appropriate 60-day and 30-day 

notice will be available to the public for comment.

9. Explain any decision to provide any payment or gift to respondents, other than 

remuneration of contractors or grantees with meaningful justification.

ED does not provide any payment or gift to respondents
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ICRAS Tracking and OMB Number: (1394.32) 1845-0013 Revised: 09/10/2013

10. Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy. If personally identifiable information 

(PII) is being collected, a Privacy Act statement should be included on the instrument. 

Please provide a citation for the Systems of Record Notice and the date a Privacy Impact 

Assessment was completed as indicated on the IC Data Form. A confidentiality statement 

with a legal citation that authorizes the pledge of confidentiality should be provided.

Requests for this information are in accordance with the following ED and OMB 

policies: Privacy Act of 1974, OMB Circular A-108 – Privacy Act Implementation –

Guidelines and Responsibilities, OMB Circular A-130 Appendix I – Federal Agency

Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB 

Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, 

OMB M-06-15 – Safeguarding Personally Identifiable Information, OM:6-104 – Privacy

Act of 1974 (Collection, Use and Protection of Personally Identifiable Information). If 

the collection is subject to the Privacy Act, the Privacy Act statement is deemed 

sufficient with respect to confidentiality. If there is no expectation of confidentiality, 

simply state that the Department makes no pledge about the confidentially of the data.

No assurance of confidentiality has been provided to respondents. The 

information collected here is available to the public as provided under the 

Privacy Act and the Freedom of Information Act.

11. Provide additional justification for any questions of a sensitive nature, such as sexual 

behavior and attitudes, religious beliefs, and other matters that are commonly considered 

private. The justification should include the reasons why the agency considers the 

questions necessary, the specific uses to be made of the information, the explanation to be 

given to persons from whom the information is requested, and any steps to be taken to 

obtain their consent.

There are no questions of a sensitive or private nature in this information 

collection activity.
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ICRAS Tracking and OMB Number: (1394.32) 1845-0013 Revised: 09/10/2013

12. Provide estimates of the hour burden of the collection of information. The statement 

should:

 Indicate the number of respondents by affected public type (federal government, 

individuals or households, private sector – businesses or other for-profit, private 

sector – not-for-profit institutions, farms, state, local or tribal governments), 

frequency of response, annual hour burden, and an explanation of how the burden 

was estimated, including identification of burden type: recordkeeping, reporting or 

third party disclosure. All narrative should be included in item 12. Unless directed to 

do so, agencies should not conduct special surveys to obtain information on which to 

base hour burden estimates. Consultation with a sample (fewer than 10) of potential 

respondents is desirable. If the hour burden on respondents is expected to vary

widely because of differences in activity, size, or complexity, show the range of 

estimated hour burden, and explain the reasons for the variance. Generally, estimates 

should not include burden hours for customary and usual business practices.

 If this request for approval covers more than one form, provide separate hour burden 

estimates for each form and aggregate the hour burdens in the ROCIS IC Burden 

Analysis Table. (The table should at minimum include Respondent types, IC activity, 

Respondent and Responses, Hours/Response, and Total Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for 

collections of information, identifying and using appropriate wage rate categories. 

The cost of contracting out or paying outside parties for information collection 

activities should not be included here. Instead, this cost should be included in Item 

14.

The total annual burden has been determined to be approximately 20,066 hours. 

This was determined by multiplying the estimated number of annual respondents 

(2,058) times the number of responses per respondent (4) times the amount of 

time (2.4375 hours) needed to collect, complete, review and submit the 

information.

Respondents 2,058

Responses x4

Total Annual Responses 8,232

Hours per Responses x2

Total Burden Hours 16,464

Recordkeepers 2,058

Hours per Recordkeeper (per 

year) x1.75

Total Hours 3,602

TOTAL ANNUAL BURDEN 

HOURS 20,066

The estimated cost to the public will be approximately $138,915.00. This was 

determined by multiplying the estimated number of respondents (2,058) times the 
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ICRAS Tracking and OMB Number: (1394.32) 1845-0013 Revised: 09/10/2013

amount of time it takes to collect, complete, review, submit and maintain the 

forms (3.75), times an average hourly wage of $18.00 per hour.

13. Provide an estimate of the total annual cost burden to respondents or record keepers 

resulting from the collection of information. (Do not include the cost of any hour burden 

shown in Items 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and start-up 

cost component (annualized over its expected useful life); and (b) a total operation 

and maintenance and purchase of services component. The estimates should take into 

account costs associated with generating, maintaining, and disclosing or providing the 

information. Include descriptions of methods used to estimate major cost factors 

including system and technology acquisition, expected useful life of capital 

equipment, the discount rate(s), and the time period over which costs will be incurred. 

Capital and start-up costs include, among other items, preparations for collecting 

information such as purchasing computers and software; monitoring, sampling, 

drilling and testing equipment; and acquiring and maintaining record storage 

facilities.

 If cost estimates are expected to vary widely, agencies should present ranges of cost 

burdens and explain the reasons for the variance. The cost of contracting out 

information collection services should be a part of this cost burden estimate. In 

developing cost burden estimates, agencies may consult with a sample of respondents 

(fewer than 10), utilize the 60-day pre-OMB submission public comment process and 

use existing economic or regulatory impact analysis associated with the rulemaking 

containing the information collection, as appropriate.

 Generally, estimates should not include purchases of equipment or services, or 

portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory

compliance with requirements not associated with the information collection, (3) for 

reasons other than to provide information or keep records for the government or (4) as 

part of customary and usual business or private practices. Also, these estimates should 

not include the hourly costs (i.e., the monetization of the hours) captured above in 

Item 12

Total Annualized Capital/Startup Cost:

Total Annual Costs (O&M): 

Total Annualized Costs Requested:

There is no additional annual cost burden to respondents or record keepers 

resulting from the collection of information.
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ICRAS Tracking and OMB Number: (1394.32) 1845-0013 Revised: 09/10/2013

14. Provide estimates of annualized cost to the Federal government. Also, provide a 

description of the method used to estimate cost, which should include quantification of 

hours, operational expenses (such as equipment, overhead, printing, and support staff), 

and any other expense that would not have been incurred without this collection of 

information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a 

single table.

ED Form 799 data is submitted online or via file transfer protocol (FTP) into the 

Financial Management System (FMS). It is estimated that the annual operating 

cost of the computer system to the Federal Government will be $123,050. The cost 

estimate was done by linking system activity to a percentage of the general ledger 

lines. The percentage was used to determine the estimated cost. The estimated 

cost is based on the FY2010 Operations Software license and security cost for 

FMS.

15. Explain the reasons for any program changes or adjustments. Generally, adjustments in 

burden result from re-estimating burden and/or from economic phenomenon outside of an 

agency’s control (e.g., correcting a burden estimate or an organic increase in the size of 

the reporting universe). Program changes result from a deliberate action that materially 

changes a collection of information and generally are result of new statute or an agency

action (e.g., changing a form, revising regulations, redefining the respondent universe, 

etc.). Burden changes should be disaggregated by type of change (i.e., adjustment, 

program change due to new statute, and/or program change due to agency discretion), 

type of collection (new, revision, extension, reinstatement with change, reinstatement 

without change) and include totals for changes in burden hours, responses and costs (if 

applicable).

ED is citing a total burden hours of 20,066. This is a decrease of 8,209 hours. The 

decrease is due to a decrease in participating lenders. There are no program changes.

Current Inventory 28,275

ED Proposed Inventory 20,066

Difference: (8,209)

16. For collections of information whose results will be published, outline plans for 

tabulation and publication. Address any complex analytical techniques that will be used. 

Provide the time schedule for the entire project, including beginning and ending dates of 

the collection of information, completion of report, publication dates, and other actions.

ED does not plan to publish for statistical use the results of the information to be 

collected. Management reports, however, will be prepared.
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ICRAS Tracking and OMB Number: (1394.32) 1845-0013 Revised: 09/10/2013

17. If seeking approval to not display the expiration date for OMB approval of the 

information collection, explain the reasons that display would be inappropriate.

The expiration date for OMB approval of the information collection will be displayed.

18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

The collection of information complies with 5CFR 1320.9.